AML/KYC Customer Risk Assessment Framework
Evaluate customer risk profiles and SAR decisions using regulatory-aligned AML/KYC frameworks
What You Can Do
You can rapidly evaluate customer risk profiles against regulatory requirements by structuring complex customer data into actionable risk ratings. The framework guides you through multi-layered risk assessment—identity verification, source of funds analysis, transaction pattern evaluation, and jurisdictional exposure—producing compliance decisions that withstand regulatory examination and support defensible SAR escalation decisions.
Features
customer identity verification, source of funds analysis, transaction patterns, and jurisdictional exposure assessment
trace ownership chains for corporate and trust accounts with regulatory-compliant structure
detect politically exposed persons and negative news connections flagging elevated risk
identify suspicious activity indicators (structuring, rapid velocity, mismatched purpose) aligned with FinCEN typologies
document risk factors and thresholds to build defensible Suspicious Activity Report filing justification
frameworks aligned with FinCEN, OCC, and FDIC standards for compliance examiner confidence
evaluate third-party financial institution relationships and inherent risk factors
automatic risk elevation for sanctioned countries, shell company structures, and vulnerable sectors
Example Output
Example 1: New Account Onboarding Risk Assessment
Customer: Acme Trading LLC (new corporate account, $500K monthly expected volume)
Risk Rating: MEDIUM-HIGH ⚠️
- Identity verification: COMPLETE (EIN matched, registered agent confirmed)
- Beneficial ownership: PARTIAL (2 of 3 UBOs identified; one offshore entity requires additional CDD)
- Source of funds: UNCLEAR (stated purpose: import/export, but source documentation insufficient)
- Transaction indicators: Potential structuring risk (multiple deposits just below $10K threshold flagged)
- PEP screening: No direct hits; one beneficial owner has adverse media (import sanctions concern)
- Recommendation: ESCALATE for enhanced due diligence; request beneficial ownership chain and source of funds documentation before account activation
Example 2: Existing Customer SAR Decision
Customer: John Smith (12-year account holder, sudden activity change)
Risk Factors Documented:
- ✓ Funds received from 8 different countries in 2-week period
- ✓ Immediate wire transfers to high-risk jurisdiction (no business purpose identified)
- ✓ Customer refuses to clarify source of funds
- ✓ Transaction velocity: $2.3M in 30 days (vs. historical $50-100K)
- ✓ Beneficial ownership: Unable to verify; customer became evasive when questioned
Compliance Decision: FILE SAR 📋
- Threshold met: Suspicious activity indicators align with FinCEN structuring and layering typologies
- Documentation complete: 4-page risk assessment attached with transaction timeline and communication records
- Regulatory confidence: Defensible decision documented for examination purposes
What's Included
- SKILL.md: complete AML/KYC framework with assessment workflows and regulatory alignment guidance
- Customer Risk Assessment Template: structured intake form capturing identity, beneficial ownership, source of funds, and transaction analysis
- SAR Documentation Checklist: step-by-step SAR filing decision criteria with risk factor thresholds
- PEP Screening Worksheet: adverse media and sanctions screening assessment with escalation triggers
- High-Risk Jurisdiction & Industry Matrix: regulatory reference list for automatic risk elevation criteria
Who It's For
- Compliance Analysts — evaluating new account onboarding and customer due diligence decisions
- AML Officers — managing risk ratings and SAR filing decisions across the customer portfolio
- Relationship Managers — documenting KYC/CDD for high-value customers before transaction approval
- Internal Audit and Compliance Teams — preparing documentation for regulatory examinations and audits
- Correspondent Banking Teams — assessing third-party financial institution risk and ongoing monitoring requirements
Best For
- New customer KYC/CDD workups — comprehensive onboarding risk assessment for account activation
- Transaction monitoring escalations — investigating customers flagged by automated monitoring systems
- Beneficial ownership verification — mapping ownership chains for corporate, trust, and LLC structures
- SAR filing decisions — documenting suspicious activity indicators and regulatory filing justification
- PEP and adverse media screening — detecting politically exposed persons and negative news connections
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